ML20236M458
| ML20236M458 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 07/10/1998 |
| From: | Dignan T ROPES & GRAY, YANKEE ATOMIC ELECTRIC CO. |
| To: | |
| References | |
| CON-#398-19301 LA, LBP-98-12, NUDOCS 9807140088 | |
| Download: ML20236M458 (12) | |
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00CKETED USHRC United States of America M 13 A10 :24 before the Nuclear Regulatory Commission k'j3jySEWiJn ADJUDIC/gl0 1 'gsF In the Matter of l YANKEE ATOMIC ELECTRIC COMPANY (Yankee Nuclear Power Station)
ON APPEAt. UNDER 10 C.F.R. $ 2.714A BY CITIZENS AWARENESS NETWORK FROM A MEMORANDUM AND ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD l DENYING STANDING TO INTERVENE i
BRIEF OF THE LICENSEE YANKEE ATOMIC ELECTRIC COMPANY 1
Thomas G. Dignan, Jr.
R. K. Gad III Ropes & Gray One International Place Boston, Massachusetts 02110 (617) 951-70.00 Attorneysfor the Licensee, Yankee Atomic Electric Company Dated: July 10,1998.
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STATEMENT OF Tile CASE Prior Proceedings.
On January 28, 1998, the Commission published a notice of opportunity for hearing under.10 C.F.R. $ 2.105 in respect of the approval of the License Termination l Plan ("LTP") for Yankee Nuclear Power Station ("YNPS") submitted by Yankee Atomic Electric Company (" Yankee"). 63 Fed. Reg. 4308,4328. On February 26 and 27, 1998, four petitions to intervene or requests for hearing were filed: by Citizens l Awareness Network, Inc. ("CAN"), by New England Coalition on Nuclear Pollution, l Inc. ("NECNP"), by Nuclear Information and Resource Service ("NIRS") and by Mr.
Adam Laipson, the Chairman of the " Franklin Regional Planning Board" (" Planning i Board").
On March 11,1998, Yankee filed an answer to each of these pleadings, contending (i) that in each case the pleader had failed to demonstrate the standing requisite to a request for a heating or intervention and (ii) that in each case the pleading had identified one or more " aspects" of the proceeding that were, in fact, beyond the scope of an LTP approval proceeding. On March 16,1998, the Staff filed an answer to the four pleadings of similar tenor. On March 25, 1998, the Planning Board filed a
" Response to Yankee Atomic Electric Company's Answer to Request for Hearing of Franklin Regional Planning Board."
On March 9,1998, a Licensing Board was convened by order of the Atomic Safety and Licensing Panel, and on March 25,1998, the Board issued an Order establishing the deadlines for the submission of amendments to the four petitions and responses thereto. On motions, these deadlines were enlarged. Amendments were served by the Planning Board, CAN, and NECNP on April 6,1998.2 Yankee filed a consolidat-ed response on April 13, 1998, and the Staff filed responses on April 14,17 and 20, l 1998. Certain additional pleadings were then filed.
! 8The Planning Board 3/25/98 Eding apparently crossed in the mail with the Board's Order.
'On the same date, NIRS filed a " notification" of its withdrawal from the proceeding and request 1
' I to be removed from the service list.
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On June 12,1998, the Board issued its Memorandum and Order concluding that none of the petitioners had demonstrated the requiredstanding. YankeeAtomic Electric Co. (Yankee Nuclear Power Station), LBP-98-12, NRC (June 26,1998) ("LBP-98-12"). LBP-98-12 was served on each of the parties by facsimile transmission.
On June'26,1998, CAN filed its " Notice of Appeal" and "Brief," which were served on Yankee by mail.
7he Facts.
Yankee notified the Commission of the permanent cessation of operation of YNPS and its permanent defueling in 1992.
In 1993, Yankee submitted a " decommissioning plan" (the " Decommissioning Plan") under the prior version of 10 C.F.R. 5 50.82. The Decommissioning Plan was approved by the Staff in early 1995. 60 Fed. Reg. 9870 (Feb. 22,1995).
In CAN v. NRC, 59 F.3d 284 (1st Cir.1995), the Court of Appeals held, in essence, that a change of opinion by the Commission on the point at which dis-mantlement activities were impermissible absent approval of a decommissioning plan constituted a " license" under the Atomic Energy Act and, therefore, entitled CAN to an opportunity for a hearing. In Yankee Atomic Electric Co. (Yankee Nuclear Power Station), CLI-95-14,42 NRC 130 (1995), the Commission determined that, on remand from the Court of Appeals decision, a new opportunity for hearing should be offered on the approval of the Decommissioning Plan itself, and CAN filed a request for hearing and petition to intervene.2 Eventually, a single contention was admitted in that proceeding, Yankee Atomic Electric Co. (Yankee Nuclear Power Station), LBP 15,44 NRC 8 (1996), and that contention was then disposed of (adversely to CAN) by summary disposition. Yankee Atomic Electric Co. (Yankee Nuclear Power Station),
$ Prior to 1995, the Commission did not view approval of a decommissioning plan to be a " license" within the meaning of $ 189a of the Atomic Energy Act, and no notice of an opportunity for a hearing had been issued. While CAN pressed repeatedly for a hearing on certain pre-approval dismantlement activities, it never explicitly sought a hearing on the Decommissioning Plan itself. Nonetheless, the Commission construed the logic of the Court of Appeals' holding to apply to the Decommissioning Plan and elected to apply it retroactively.
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LBP-9618,44 NRC 86 (1996). Commission review was denied. Yankee Atomic Electric Co. (Yankee Nuclear Power Station), CLI-96-9,44 NRC 112 (1996). CAN did not seek judicial review. The Decommissioning Plan was therefore " approved" a second time.4 In , July,1996, the Commission amended $ 50.82. 61 Fed. Reg. 39,278 (July 29, 1996). One effect of the amendment was to eliminate any requirement of Commission j approval of a decommissioning plan as a condition precedent to a licensee's authority to begin dismantlement. For plants (such as YNPS) as to which decommissioning plan approval proceedings were on-going, the Commission decreed:
"For power reactor licensees whose decommissioning plan approval activities have been relegated to notice of opportunity for a hearing under subpart G of 10 CFR part 2, the public meeting convened and 90-day delay of major decommissioning activities required in paragraphs i (a)(4)(ii) and (a)(5) of this section shall not apply, and any orders arising from proceedings under subpart G of 10 CFR part 2 shall continue and remain in effect absent any orders from the Commission."
- CAN's failure to understand that the activities that were " licensed" by the Decommissioning Plan approval and the fact that the LTP approval authorizes no activities (but merely establishes the site survey plan as definitive for demonstrating releasability) is no doubt why CAN cannot understand that the fact that it was accorded standing in the prior case does not entitle it automatically to standing in this case. See CAN Br. at 5-6. The difference has nothing to do with the fact that anyone thinks that CAN's " concerns have . . . decreased." Id. The difference is that what grounded standing in the prior case (the potential for off-site impacts from activities to be licensed) does not exist in this case.
Indeed, if CAN were logically consistent, its professed belief that an LTP proceeding is identical in scope to what was formally covered by a decommissioning plan (implicit in the argument made in CAN Br at 9-10) would require it to confess that it has no remaining hearing rights, since CAN was granted a hearing on the decommissioning plan, which CAN lost. No debate about what AEA $ 189a applies to and does not apply to has ever embraced the notion that an intervenor is entitled to two hearings on the same subject.
In passing, it may also be observed that CAN's demand that a hearing on dry cask storage of spent fuel should be granted in this proceeding because ('m effect) the Board in the prior case promised one (CANBr. at 8-9) is entirely misplaced. The Board in the prior case promised nothing;it merely observed that, as a matter of law, the outcome of that case would have no effect on whether Yankee could or would employ dry cask storage technologies. CAN's " rights" under AEA $ 189a with respect to a license under 10 C.F.R. $ 70.40 will become ripe when, as and if Yankee app'.ies for such a license (which it has not yet done and may never do); CAN's " rights" under $ 189a with respect to the general license under 10 C.F.R. $ 72.210 were exhausted when the Commission promulgated that rule; and CAN's "righ s" under AEA $ 189a with respect to the heavy loads Technical Specification amendment were exhausted when the Commission published a notice of opportunity for a hearing and CAN elected to let the issue go by.
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10 C.F.R. $ 50.82 (Introduction) (1996). No Commission order otherwise affecting the scope of the approval of the Decommissioning Plart has ever been issued.
ARGUMENT !
I. CAN'S APPEAL IS UNTIMELY AND SilOULD BE DISMISSED AS SUcII.
CAN's appeal purports to lie under 10 C.F.R. $ 2.714a, which provides that !
- [A]n order of [the ASLB] designated to rule on petitions for leave to I intervene and/or requests for hearing may be appealed, in accordance with the provisions of this section, to the Commission within ten (10) days after service of the order."
10 C.F.R. $ 2.714a(a). LBP-98-12 was served on CAN on June 12,1998, by facsimile, followed by mailing of a paper copy of the same decision. CAN's notice of appeal and brief were therefore required to be filed by CAN on or before June 22,1998. On June 26'h, the deadline had passed four days earlier.
CAN possibly asserts that the " extra time" provision of 10 C.F.R. $ 2.710 applies.5 The purpose of that rule is to take into account the time between mailing and receipt, so that a party's time is not rtmning while the party has no notice of the event to which it is permitted or obliged to respond. Neither by its terms nor its logic does 5 2.710 apply where the predicate paper was served by fax. CAN's appeal is therefore untimely and it should be dismissed on that ground.'
IL TIIE LICENSING BOARD CORRECFLY APPLIED TIIE PROPER LEGAL STAN-DARDS IN RULING TIIAT CAN IIAD NOT DEMONSTRATED TIIAT ITS MEMBER KATZ HAD STANDING TO INTERVENE IN Tills PROCEEDING.
In this case, CAN sought to establish standing for the organization by demonstrat-ing standing on the part of one of its members (Debbie Katz). " Representative" 5"Whenever a party has the right or is required to do some act within a prescribed period after the service of a notice or other paper upon him or her and the notice or paper is served upon by mail, five (5) days shall be added to the prescribed period."
'While service by fax is not specifically enumerated in 10 C.F.R. $ 2.712(c), it is specifically recognized as an accepted means of serveie in $ 2.712(d)(1).
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l standing recognizes that an incorporated advocacy group may have standing to inter-vene to represent, not its own interests, but the interests of members who have an interest which will be affected. Florida Power & Light Co. (St. Lucie Nuclear Plant, Units 1 and 2), CLf-89-21, 30 NRC 325, 329 (1989); Public Service Company ofIndiana l
, (Marble Hill Nuclear Generating Station, Units 1 and 2), ALAB-322, 3 NRC 328 l
(1976). To achieve " representative" standing, the petitioner must identify by name and address at least one member who wishes to be represented by the organization and who has the necessary interest. Virginia Electric & Power Co. (North Anna Nuclear Power Station, Units 1 and 2), ALAB-536,9 NRC 402,404 (1979); Detroit Edison Co. (Enrico Fermi Atomic Power Plant, Unit 2), LBP-79-1,9 NRC 73,77 (1979). CAN sought to carry its factual burden of demonstrating Katz's standing (Consumers Power Co.
(Midland Plant, Units 1 and 2), LBP-78-27,8 NRC 275,277 (1978)) by submitting two affidavits. One, by Katz, established that she resides about 6 miles from the YNPS site and has " concerns" about several things, most notably (i) spent fuel management and (ii) historical offsite releases. The second (by one David Lochbaum) was offered by a
! presumptive " expert" in order to demonstrate that Katz's concerns were not speculative; l
however, Lochbaum's affidavit was limited to matters relating to the on-site storage and disposal of spent fuel.
A. The Licensing Board Correctly Ruled that CAN May Not Predicate Standing Based on PotentialImpacts Allegedly Arising Out of the On-Site Storage of Spent Fuel.
i Katz's primary concern before the Board, as well as before this Commission, l relates to the on-site storage and handling of spent fuel:
l "CAN's representative member also expresses concern in her affidavit l about . . . activities attendant on the creation of an ISFSL . . . CAN's affiant is concerned about the impacts of an accident at Yankee Rowe during implementation of the LTP. YAEC's proposal to use dry cask storage of irradiated fuel poses a risk of a cask drop accident and melt down, with potentially severe offsite consequences, as supported by the affidavit of David Lochbaum."
CAN Br. at 4-5. However, as the Licensing Board correctly ruled, these " concerns" do not sum to standing, because the approval or disapproval of the LTP has no effect on
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what Yankee does or may do concerning the on-site management of spent fuel. LBP 98-12 at 7,12. This Commission itself has stated:
"[T]he NRC definiuon of deconunissioning excludes interim storage of spent reactor fuel."
l 61 Fed. Reg. 39,278, at 39,293 Ouly 29,1996). The LTP regulation,10 C.F.R.
l $ 50.82(a)(9)(ii), does not require the LTP to contain any information regarding spent j fuel management. In promulgating revised $ 50.82, the Commission described the )
1 function of the LTP approval in these terms: )
"The requirement for submittal of a termination plan is retained in the final rule because the NRC must make decisions, required in the current rule on the decommissioning plan, regarding (1) the licensee's plan for assuring that adequate funds will be available for final site release; (2) radiatien release criteria for license termination, and (3) adequacy of the final survey required to verify that these release criteria have been met."
61 Fed. Reg. 39,278 at 39,289 Quly 29,1996). The absence of any review of spent fuel management was intentional: j "The existing rule, as well as the proposed rule, consider the storage and l maintenance of spent fuel as an operational consideration and provide separate part 50 requirements for this purpose. Regarding maintaining (
the capability to handle the fuel for dry cask storage, these requirements are maintained in 10 CFR part 72."
Id. at 39,292.
Approval of the LTP would not give Yankee, and Yankee does not need, any additional license or authority for spent fuel management: Yankee already possesses a license under 10 C.F.R., Part 50 sufficient to authorize continued use of the existing spent fuel pool,7 and it already possesses a general license under 10 C.F.R. $ 72.210 to move fuel to approved dry casks (when, as and if Yankee decides that such movement
'Certain modifications to the spent fuel pool (removing its dependence on other plant systems) were previously approved when the Decommissioning Plan was approved or were performed under the authority of 10 C.F.R. $ 50.59 and,in any event, have already been implemented. Yankee's existing Part 50 license also authorizes the storage of GTCC in the pool.
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l should be made).8 Yankee already also has authority to move " heavy loads" over the spent fuel pool? Should Yankee decide in the future to seek a separate Independent j I
Spent Fuel Storage Installation license under 10 C.F.R. $ 72.40, the Regulations provide {
that an application must be filed and a notice of opportunity for hearing vill issue on j that application, but no such application has yet been filed (or prepared). In short, l whether the LTP were to be approved or disapproved will work no change in either )
Yankee's existing license authority or its management of spent fuel.
As a consequence, none of the " accidents" that the Lochbaum affidavit purports to validate for CAN's member's " concern" an.ount to an " injury [that]is likely to be l
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redressed by a favorable decision." Yankee Atomic Electric Co. (Yankee Nuclear Power l Station), CLI-96-1,43 NRC 1,6 (1996)." Ms. Katz therefore has failed to demonstrate i
'CAN apparently believes that it may use the LTP proceeding as a vehicle for asking the Cc,m-mission to revisit and revise-or perhaps rescind-the p omulgation of $ 72.210. See CANBr. at 8-9: "By NRC permitting YAEC to create an ISFSI under a part 50 license, NRC eviscerates CAN's hearings rights and the environmental requirements of Part 72." Prescinding from the fact that CAN rather l severely misunderstands the application of both Atomic Energy Act $ 189a and NEPA to " general licenses," the fact of the matter for present purposes is that one may not posit standing based on the impact of Prr, c eding A, which does not result in permission to do Action A, by contending that some other regult- 6at obv e any such permission is invalid. Even if $ 72.210 were not on the books, approval of tk LTP would not authorize any storage of any spent fuel by any means,
' Letter, Morton B. Fairtile to Frederick N. Williams, dated June 17,1998, re: " Issuance of Amendment No.149 to Facility Operating License (Possession only) No. DPR Yankee Nuclear Power Station (TAC No. M99529" and enclosures; 63 Fed. Reg. 35,986,36,002. A notice of opportunity for hearing on this Technical Specification amendment was published over ten months ago. See 62 Fed.
Reg. 54,866, 54,879 (October 22, 1997). The time for filing requests for hearing and petitions to intervene on that amendment expired November 21,1997. Id. at 54,867. CAN did not request a hearing or petition to intervene in that matter.
"The Commission employs judicial concepts of " standing" for purposes of seeking intervention in adjudicatory proceedings. Portland General Electric Co. (Pebble Springs Nuclear Plant, Units 1 and 2),
CLI 76-27,4 NRC 610,614 (1976). "To have ' standing in court', one must satisfy two tests. First, one must allege some injury that has occtarred or will probably resultfrom the action involved." Portland l Ceneral Electric Co. (Pebble Springs Nuclear Plant, Units 1 and 2), CLI-76-27,4 NRC 610, 613 (1976)
(emphasis added). The test is "whether a cognizable interest of the petitioner might be adversely affected -
if the proceeding has one outcome rather than another." Public Service Company ofIndiana (Marble Hill Nuclear Generating Station, Units 1 and 2), CLI-80-10,11 NRC 438,439 (1980).
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e l her standing to litigate spent fuel issues, for want of which CAN has failed to demonstrate standing as her representative to litigate those issues.
B. The Licensing Board Correctly Ruled that CAN May Not Predicate Standing Based on Potential Impacts Allegedly Arising Out of Previous Off-Site Releases of Radioactive Materials.
Though far from clear, it appears that CAN wishes to litigate in the LTP proceeding some issues of fact or law concerning prior releases of radioactive materials off-site (i.e.,into the Deerfield River). CAN does not contend that these releases were other than those permitted by the YNPS operating license. Nor does CAN by any-thing but the vaguest of allegations demonstrate injury-in-fact to Knz, much less injury-in-fact to Katz that is " distinct and palpable" to Katz and different from any impact on the public generally. Transnuclear Inc., CLI-77-24, 6 NRC 525, 531 (1977)."
Prescinding from these defects, however, CAN once again misapprehends the nature of an LTP or its approval. The LTP does not authorize any action, nor does it amount to (or afford an opportunity for) enforcement of existing regulations with respect to off-site releases-even in the hypothetical case of a licensee whose historical off-site releases exceeded licensed limits. The function of the LTP, rather, is the approval of the plan by which the licensee intends to demonstrate compliance with the Commission's site release criteria. The notion that a licensee might have to recover prior off-site emissions is irretrievably antithetical to the concept of those prior releases having been " permitted" in the first place. Paripassu, any obligation that a licensee might have to remediate prior unpermitted off-site releases is not affected, one way or another, by approval of an LTP.
"*0ne focus of the ' injury in fact' test is the concept that a claim will not normally be entertained if the ' asserted harm is "a generalized grievance" shared in substantially equal measure by all or a large class of citizens' . . . . Thus, even if there is a generalized asserted harm, the Petitioners must still show a distinct andpdpable harm to them." (Emphasis added.)
C. The Licensing Board Correctly Ruled that CAN May Not Predicate Standing Based on Potential Impacts Allegedly Arising Out of An Erroneous Statement of the Governing Legal Rule.
Giving CAN the benefit of the doubt, the Licensing Board addressed the question of whether CAN might predicate standing based on its assertion that one element of the site survey plan was contrary to legal requirements-though there was nothing in the record that remotely approached demonstrating a potential for " distinct and palpable" harm to Katz from this point. The Board correctly ruled that CAN erred as a matter of law in stating the asserted legal requirement.
On appeal, CAN appears to have abandoned its contention below," and now contends, in effect, that the Commission is obliged to require Yankee to employ a standard of 15 mrem /yr TEDE (average member of the critical population group),
rather than 25 mrem /yr TEDE (average member of the critical population group).
CAN Br. at 9. The source of a supposed 15 mrem /yr requirement is unclear; the dictate of the 25 mrem /yr standard is clear;" Yankee (in any event, and whether obliged to or not), is proposing to use a 15 mrem /yr standard; and this point was not "Below, CAN contended that, in meeting the requirement stated in units of Total Effective Dose Equivalent (TEDE) that might be received by the average member of the critical population group of persons exposed to residual contamination at the site, a licensee is obliged to assume that a given person stands over a given square foot of land, outdoors, for 8,766 hours0.00887 days <br />0.213 hours <br />0.00127 weeks <br />2.91463e-4 months <br /> per year. Based on the Commission's regulation, its Statement of Considerations in promulgating the regulation, and the NUREG on which the regulation was based, the Licensing Board held to the contrary. The Licensing Board's ruling was plainly correct, for the reasons stated below in Yankee's " Response of Yankee Atomic Electric Company to Amendments to Petitions to Intervene" at 24-29, and on appeal CAN no longer presses this argument.
"10 C.F.R. $ 20.1402, as promulgated by 62 Fed. Reg. 39,058 (July 21,1997): "A site will be considered acceptable for unrestricted use if the residual radioactivity that is distinguishable from background radiation results in a TEDE to an average member of the critical group that does not exceed 25 mrem (0.25 mSv) per year . . .
Possibly it is CAN's contention that, if a licensee proposes to do more than the minimum required by the regulations, its voluntary undertaking should be metamorphosed into a binding obligation. We can think of no more effective way to be absolutely certain that licensees will never do or offer to do more than the minimum required.
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raised below in any event and may, therefore, not be raised for the first time on l
appeal." .
(- CONCLUSION Insofar as.it denied standing to intervene as a party to CAN, LBP-98-12 should be affirmed.'
Respeqfully submitted, b n ,
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i Thomas G. Dih Jr. ,x R. K. Gad III l Ropes & Gray One International Place Boston, Massachusetts 02110 (617) 951-7000 Dated: July 10,1998.
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" Yankee Atomic Electric Co. (Yankee Nudear Power Station), CLI 96-7,43 NRC 235,260 & n.19 (1996).
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S (ddRTIFICATE OF[SFhVICE$
I, Robert K. Gad III, one of the attorneys for Yankee Atomic Electric Company, do hereby !
l certify that by where indicated onanJuly [Q,1998, asterisk, by facsimileI transmission; served the as follows: within brief in this 98 J113matter by :Lz United Statel i
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I Ut r b o. J v--.~ -
l Shirley Ann Jackson, Esqu.ire Greta J. Dicus RULFWI O ,wD l Chairman Commissioner ADJUD O w n m F F U.S.N.R.C. U.S.N.R.C. 1 Washington, D.C. 20555 Washington, D.C. 20555 )
Nils J. Diaz Edward McGaffigan, Jr.
Commissioner Commissioner U.S.N.R.C. U.S.N.R.C.
Washington, D.C. 20555 Washington, D.C. 20555 i?i.kunsin[jlobbh The Hon. James P. Gleason, Chairman The Hon. Thomas D. Murphy Administrative Judge Administrative Judge i Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel !
U.S.N.R.C. U.S.N.R.C. I Washington, D.C. 20555 Washington, D.C. 20555 ;
FAX: 301-415-5599 FAX: 301-415-5599 ;
The Hon. Dr. Thomas S. Elleman Administrative Judge 704 Davidson Street Raleigh, North Carolina 27609 FAX: 919-782-7975 Qihy *E <
Diane Curran, Esquire Mr. Adam Laipson, Chairman )
Harmon, Curran, Spielberg & Eisenberg, LLP Franklin Regional Planning Board l 2001 S Street, N.W., Suite 430 425 Main Street Washington, D.C. 20009 Greenfield, Massachusetts 01301 l Attorneyfor NECNP FAX: 413-774-1195 Ms. Deborah B. Katz Anne B. Hodgdon, Esquire Citizens Awareness Network, Inc. Marian L Zobler, Esquire Post Office Box 3023 Office of the General Counsel Charlemont, MA 01339 U. S. Nuclear Regulatory Commission On Behalf of CAN Washington, D.C. 20555 FAX: 301415-3725 Attorneysfor the NRC Staff
[o M '
s Office of Commission Appellate Adjudication Office of the Secretary U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Washingt.on, D.C. 20555 f " FAX: 301-71f-16,72 ,g f', /
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R. K. Gad III /
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